IR 05000298/1979010
| ML19247A277 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/04/1979 |
| From: | Cupp E, Johnson E, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19225C463 | List: |
| References | |
| FOIA-79-98 50-298-79-10, NUDOCS 7907300484 | |
| Download: ML19247A277 (8) | |
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U. S. NUCII.AR REGULATORT CCMKISSICN OFFICE 07 INSPECTION AND EHFORCEFENT REGICN IV
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Report No. 50-298/79-10
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Docket No. 50-298 License No. DPR-46 Licensee:
Nebraska Public Power District P. O. Box 499 Colur. bus, Nebraska 68601 7acility Nane:
Cooper Nuclear Station
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Inspection At:
Cooper Nuclear Statica, Ner.ah.a Ccunty, Nebraska Inapection Conducted: May 1-4 and 14-15, 1979
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G/>l,a 2:i= 1pa1 Inspector:
E. H..!chn.scu, Reactor Inspector Data
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E. A. Cupp, Reactor Inspec:or (May 14-15, 1979 only)
Date Approved by:
_N d;/F/74 T. F. Westerman, Chief, Reactor Proj ects Saction Date Insoection Su_ arv Inspection on May 1-4 and 14-15, 1979 (Report No. 50-298/79-10)
Areas Insoected: Rou c 2.ne, unannounced inspection of the licensee's actions on IE3 79-08 " Events Relevant to Boiling Water Pcuer Reactors Identified During Three Mile Islant Incident." The inspection involved sixty-one (61) inspector-hours on site by two (2) NRC inspectors.
Results: One ita= ou nonce =pliance (Infraction - failure to perfor.s to safety related =aintenance activity using the latest approved revision of the appropriate procedure - Details, paragrapia 11) was identified.
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DETAILS
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Persoru Contacted L. F. 32dcar, Electrical Engineer P. J. Borer, Assistant to the Station Superintendent R. Reimrs% Shif t supervisor P. F. Doan, Macb=" % i Engineer
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L F. Gilbert, Training Coordinator H. A. Jantzen, Instr *.:nast and Controls Supat risor
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L. I. Lawrence, Maintenance Supervisor
- L. C. Lessor, Station Superintendent C. R. Noyas, Engineering Supervisor R. W. Seier, QA Supervisor P. V. Thonsson, Assistant to the Station Superintendant M. G. Willians, Operations Supervisor
- Present at the exit incarview.
In addition to the above technical and supervisory personnel, the inspector held discussions with various naistenance, operations, technical support and adninistrative nenbers of the licensee's staf f.
1.
_ Plant Ststus During the first part of this inspection the licensee was ccupleting pre-parations for a reactor startup following a four week refuelint outsgs.
During the second part of the inspection routine power operatir es vers in progress at approxi=stely 60 percent power.
2.
Objective of t5e Insoection on April 14, 1979 the SRC issued IE 3n11= tin 79-08 " Events Relevant to soiling Water Power Reactors Identified During Three Mile Island Incident" to all 3WR licensee's. This bulletin directed that the licenses conduct a review of systems and procedures as well as e=phasize operating instructions to operators, to to ensure that the conditions and/or operating errors that contributed to the TMI inc2ent are not present at his facility.
The licensee responded to this bulletin on April 25, 1979 (NPPD ler J. M. Pilant to NRC Region IV K. V. Seyfrit).
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The purpose of this inspection was to review the licensee's response to the IE3 and the perfor:2 and independent verification of the operability of the engineered safeguards features systens. The specific itens inspected are detailed in paragraphs 3 thru 11 below.
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3.
Review of Coerators Training Relative to IIB 79-03
The purpose of this inspection effort was to review the training provided by the licensee relative to the actions required in IEB 79-08.
The description of the events of the TMI-2 incident were routed to each operator along with a memorandum of instruction written by plant management to renisd the operators of their responsibilities toward safe plant operations.
The contents of this =c=orsudum were noted to be as described in the licensee's respense to IES 79-03.
In addition to the above, the station
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superintendent held a discussion session with each operating shift to reiterate the above and confics that each operator, understood the apparent cperational errors made during the TMI-2 incident and the actions. that should have been taken to preclude this incident.
The inspector had no further questions regarding this area.
4.
C:=rarisca of E37 Ivs em ali?nsents with Process Drawings The objective of this inspection effort was to compare the system alignments called out in cperating procadures for the engineered safeguards features Sys:ces (IS?) a;ni :t the valve align =ents shown on the licensee's as built process drawings.
The inspector perf:::ad a detailed review of the following IEF syst as using the procedures sud drawings indicated below:
High Pressure Coolant Injection - Jystem Operating Procedure (S.O.P)
2.2.33; Process and In:.trumentation Drawing (P&ID) 2044, 2041, 2049 Reactor Core Isolation Cooling - SOP 2.2.67, P&ID 2043, 2041, 2060 Autocatic Depressurization System - SOP 2.2.1, l'&ID 2027 Core Spray - SOP 2.2.9, P&ID 2045 Residual Heat Removal (Low Pressure Coolant Injection) - SCP 2.2.34 and 2.2.69, P&ID 2040 Diesel Generator Starting ~ Air - SGP 2.2.20, P&ID 2077 Standby Liquid Control - SOP 2.2.74, P&ID 2045 Residual Heat Removal Service Water - SOP 2.2.70, P&ID 2006, 2036 Reactor Equipment Cooling - SOP 2.2.65, P&ID 2031
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Diesel ve:erator Tuel Oil - SOP 2.2.20, P&ID 2077, 2011 Standby Gas Treatment System - SOP 2.2.73, P&ID 2020, 2022, 2037 Service Water - SOP 2.2.71, P&ID 2006 P00ROR E
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No items of noncompliance or devistions were noted in this area of the
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inspection.
The inspecter did note the following items ti st were brought to"the attention of the licensee for his review and correction:
a.
Sectivt VII.C.3 of procedur: 2.2.9 directs the operators actions re;a: ding the c;eration of the core spray :7 sten te 22 autt=2 tic ini::iation signal. This section of the procedure should stress the use of multiple vessel level indicators.
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b.
In the valve alignment checklist for procedur 2.2.71 it was noted that valve S'4-125 was specified to be locked open whereas the P&lD showed this valve to be loched closed. The co=pleted valve ali;;nsent checklist perfor=ed prior to the reactor startup had a te=porary change to the pr:cedure to check this valve locked closed.
An indmpendent valve 7:sition verification by an N?.C in:pector determined that this valve was lac 2ed c]osed.
A per=anent pr:cadure change is in p 03ress for this ites.
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c.
In reviewin; the vsive alignment procedure for the standby liquid
- catrol s7, tem, it uss noted that the latesu reviaics to the drawing (ravisien m.
had d212 ted th; lached closed requi-a-a t for valve SLC-23 irem th 3 r.
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Tia latast operatin; procedure showed this valv: :s throttled open. Although the down str:ss valves SLC-25 and 26 ::: closed per the valve alignment checklist, these valves are not locked in the closed position to provide an equivalent level of control since SLC-23 now is not locked closed.
This ites was discussed with the licensee and the inspector indicated that it would remain unresolved pending analysis by the licenser (Unresolved item 7910-1).
5.
Review of Surveillance Procedures and Surveillance Test Results for ESF Systems The objective of this inspection effort was to resiew in detail, the licensee's surveillance procedures for ISF sy.=tems to ensure that sufficient procedural controls existed to ensure that at the cocpletion of the test, the system had been restored to its operable (or standby) condition. The inspector also reviewed the latest completed surveillance test for each
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of the procedures reviewed to ensure that the acceptance criteria for system /
component operability had been met.
This review constituted 100 percent of the technical specification required tests to verify system operability for each of the ESF systems reviewed.
This area of the inspection consisted of a review of 107 surveillince peccedures and the latest cespleted test results for the ESF systems listed in paragraph 4 above.
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The inspector noted that the acceptance criteria for each completed test
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reviewed had been net.
Several discrepancies of an editorial nature were
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noted in the review of the precedurse. These itens were coccunicated to a licensee representative to be included in the next revision to the procedures.
During the review of the surveillance procedures the inspector noted that many procedures contained a procedural step requiring the operator to restore the syste: lineup to nor:sl or to the standby ecndition specified in the syste:s operating procedure. This type of statenant was present in addition --
to the procedural stens which restored individual valves or control switches proper positions (wnen suca valves anc switenes were repostatonec to cael:
during the test).
It was apparent to the inspector that such a general
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star 2 ment was intended as a final raview hy the npa n c a r nf the gye r m status. The inspector expressed his concern that his type of procedural requirenent does not provide sufficient specific guidance to ensure that the operator checks the system r-turned to service in a uniforn nanner. Tia inspector indicated that a specific chechlist for checking the systans aligned for standby, or the appr:prian procedural steps :dded :.: ca procedure, would acccnoli:h this. This iten vill receive cott:.nued follow-up during a subsequent inspectien.
(0 pen Iten 7910-3)
The inspector had no further questions in this area.
6.
Ecuiceent Tactic 2 ?ree-durp 7be purpose of this inspection effort was to coafir:s that. de licensee's
- rocedures fer cat. ion and hold tags on equip.
- :ent were such dat tags would not be allowed to obsure indicating lights, =eters or centrol switch positions
- nch that operators could not readily deternine plant c:nditions.
Based on nuserous previous observations at this facility 2nd a discussion of tse tagging procedure with the operstions supervisor ' e inspector deteccised that caution and hold tags are placed on cont.ol boards in such a ma e tr that lights and switches are not obscured.
In general this naans that such tags are rolled up and tucked underneath the control switch on which they are attached.
The inspector had no further questions on this natter.
7.
Use of BPCI/RCIC During Routine Operational Transients The purpose of this inspection effort was to determine if the EPCI or RCIC systens are routinely used to sugnent normal feedwater flow during routine operational events which may induce a reactor water level tracsient.
In discussions with several senbers of the licensee's operations staff it na deternised that EPCI and RCIC have automatically operated (in addition to g q. 3 pn a
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required surveillance testing) only in response to an actual reactor water, level low signal (-37 inchas) nn arveral nrruions due to a main turbine trip or loss of feedwater/ reactor trip. Those events consititute transients for which HPCI and RCIC initiations are expected. The HFCI and RCIC syster.s are not used as a routine augment to the feedwater syste:s by the operators to maintain vessel level.
The inspector had no further questions on this matter.
8.
Valve Ali---mt Verification
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The objective of this inspection effort was to verify the alig-* t of valving for the flowpaths of the safety related postions of the ESF systema listed in paragraph 4 abcve. This independent verification was performed using the valve sligunent checklists contained in the system operating peocedures that had been proviously verified against the peacess and instrunentation drawing (see paragraph 4 above) actual visual check of valve positions.
In addition to the independeat valve alignment verification the inspector reviewed the valve alignment checklists used for the valve align =ents per:ornec at ene ena or one current reruenng outage to oene:mne taat alt discrepancies were resolved. The insnector had no questio s in this area.
- To itens of necce=pliance or deviet;u.a sete ated in this area of the inspection.
Several discrepancies vara noted that were brought to the attention of the licensee for co-rection.
These i tems are detailed below.
Standby ;as treatment valve SGT 49 (Fan cross connect valve) was specified on t.he process and instrumenta tion drawins and tbc ve.ve che cklis t to be locked open. The valve was verified to be ir. the open position as required but was not sealed against inadvertent operatico, nor was the valve listed in the valve seals log to be sealed. The inspector inferred the licensee of this fact sad indicated that this ites requ:. red review to determine
the reason for requiring the valve to be locked in position. This iters will rannin unrt::le=d pending review by the licewe (unresolved ites 7910-2).
It was also noted that valve DGSA-15, diesel genertor 91 starting air co pressos uu. tie was 6 pan whereas the valve lineup checklist of pro-cedure 2.2.20 states that this valve is to be shut for cornal operation (the valve is not however specified to be sealed).
This valve is one of two series valves in ene cross connect. 11a= aud== the wther valve w.. shut the system operation was not icipaired. A licensee representative took immediate action and closed the valve.
9.
Administrative Controls for the Return of ESF Svstems to Service following Test and Maintecance The objective of this inspection effort was to review the licensee's adninistrative controls for L' c setuu of r.C" systems to.ervice following u
test and/or caintena.ce activities.
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During inspection 50-298/77-15 (Details, parsgraph 12) the inspector
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discussed the control of valves designated on process drawings as locked.
These are valves whose position ir critical to the proper operation of ESF systems. The licensee responded ts these concerns by revising his equipment control practices to include a valve seals log. This log contains a listing, by system, of valves that. are designated 4.
lud.:d la pv=ltlua.
F sh of these valves is sealed by a serialized lead seal to present inadvertent valve operation. The renoval of a seal is autaorized only by the shift supervisor or by a specific step of a surveillance procedure. The removed seal is returned to the shift supervisor and recorded in the valve seals logt--
Reinstallation following =aintenance or test is directed by the shif t oupervisor and the ac= accial uo l.c.
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Following all maintenance activities involving an EST syste:s the licensee rec.uires that an appropriate surveillan : procedure operability test be perfor=ed prior to designating that system as " restored to normal" on the
=aintenance work request.
Additionally the inspector reviewed the licensee's surveillance test progras for all 237 syste=s to ensure that following the completion of the test the s7 stem had been restored to its proper operational (or standby)
c mdi. ion. This inspection effcet is detailed in paragraph 5 above.
This in:pactor had no further questions on this =atter.
10.
Restoration of Ecuiccent and Systems following an Extended Outare The purpose of thxs inspection effort was to examine the methods used by the licensee to control the restoration of equipment and systems following an extended cutage to assure that all safety related systems are made fully ready prior to plant startup or heat up.
During the first part of this inspection, the licensee was in the last week of a refueling outage
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thus affording the inspector an opportunity to review the control sethods for equipment and system restoration arrumily in uv.
The "nllowing ite=s were noted.
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A master startup checklist had been prepared for the restoration frets this outage. This checklist contained a list. of all system fur which valve lineup checks are to be perfor=ed; all surveillance tests that must be cc=pleted prior to, and during startup; and all plant operating procedures that are to be perfor=ed for equipment lineup:.
E2ch of the startup checklisc line ite=s was to be signed off by the shift supervisor upon completion. Final approval for plant startup is recor..eeded by the on site review cocrsittae and approved by the station superintendent.
The individual system valve align =ent checklists contains a cover sheet to 114..11 41.,cccpascics (=e. tc rir.1 d i = c r=p== i= = su ch -- - 4 - 4 - a * - ' * n ;:-
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or align =ent discrepancies caused by plant maintenance) noted during the
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alig:=ent. When each of these discrepancies is corrected the entire chech-list is reviewed by the shif t supervisor who then certifies the system as ready for startup.
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The inspector had no further questions in this area.
11.
Facility Tour During both parts of the inspection a cour of the facility was conducted
to note plant conditions and the status of maintenance in progress and-to
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review system operations to determine if any abnormalities were present.
During the facility tour on May 1, 1979, the inspector noted that : check of the setpoint on a standby liquid control pump discharge re.11ef valve was in progress by operations department personnel. The inspector questioned the operators regarding this activity and noted that =aintenance procedure 7.2.35 revision I was being used in the performance of this check. The inspector noted fron the controlled copy of the licensee's procedures that the correct revision for this procedure is revision two of harch 1978.
. Section 2.6 of the licensee's quality assurance ranual requires that procedures (including the latest revision) Le controlled and distributed to the location where the activity is perfor=ed. The failure to use the l arase revi sinn in the performance of safety related maintenance is an iten of concompliance.
12.
Unresolved Ite=s Unresolved ite=s are natters about which nore information is required to ascertain whether they are acceptable, items of nonce =pliance oc deviations.
The following unresolved items were identified during this inspection.
7910-1 SELC valve 23 (paragraph 4)
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7910-2 SBGT valve 49 (Parsgraph 8)
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13.
Exit Interview
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An exit interview was held at the cecclusion of each part of the inspection with the station Superintendent. The findings indicated above were discussed.
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